CUNA: More Time Necessary for Reg Z Review Comments

WASHINGTON-CUNA Senior Assistant General Counsel Jeff Bloch wrote a letter to the Federal Reserve dated Feb. 15, requesting more time to put together comments on the review of the Regulation Z open-end credit rules. The current deadline for comment is March 28, but CUNA has asked that be extended to May 27. He pointed out, “Since the [Advance Notice of Proposed Rulemaking] was issued by the Fed on December 3, 2004, and published in the Federal Register on December 8, 2004, CUNA has been actively involved in soliciting feedback from our member credit unions on how the open-end credit rules can be amended to accomplish the dual goals of making the required disclosures easier for consumers to understand, as well as minimizing additional burdens for credit unions or possibly even reducing current burdens. We are optimistic that these goals can be accomplished, and CUNA enthusiastically embraces the opportunity to participate in this process.” However, a number of issues have been raised by the Fed that stir up new issues. “Many of the issues raised in the ANPR affect other issues, such as closed-end lending and require comparisons between different types of open-end credit, such as credit cards and home equity lines of credit,” Bloch wrote. “We believe the comment process will be improved if the Fed allows additional time for affected parties to develop meaningful comments on these important issues. In light of this, we believe an extension of the comment period for at least an additional sixty days is warranted.”